top of page

anti-corruption policy

1. purpose

travel one embraces ethics, transparency, and law compliance as core pillars of its operations in tourism.
this anti-corruption policy aims to guide the conduct of all employees, executives, suppliers, partners, and third parties, ensuring behavior aligned with current laws and the principles of integrity and honesty.
this document supports the prevention of illegal practices such as corruption, bribery, money laundering, and fraud, based on the anti-corruption law (Law 12.846/2013), money laundering law (Law 9.613/1998), lgpd (Law 13.709/2018), among other applicable laws.

2. scope

this policy applies to all members of travel one: directors, managers, employees, service providers, suppliers, and business partners. all must observe and comply with the principles outlined in this document, as well as the company’s code of conduct.

3. definitions

public official: anyone who holds a public position, job, or function, even temporarily or unpaid, including political party members and candidates.

corruption: offering, promising, authorizing, granting, or receiving undue advantage, directly or indirectly, to influence a decision or gain favor.

bribery: a form of corruption involving payments or benefits given to influence third-party decisions.

fraud: any dishonest act aimed at obtaining undue advantage, hiding facts, or harming others.

thing of value: money, gifts, favors, entertainment, job opportunities, or any other kind of benefit.

third parties: individuals or entities not part of the company who act on its behalf or interact with clients, partners, or public authorities.

4. prohibited conduct and principles it is strictly forbidden under any circumstance:

offer, promise, or accept bribes, kickbacks, or improper advantages;

use intermediaries to carry out corrupt practices;

make facilitation payments to public or private agents;

participate in fraud in bids, tenders, or administrative procedures;

use company resources to fund political campaigns or candidates;

interfere in audits, inspections, or investigations.

5. relations with public officials and private sector all interactions with public officials must follow transparency and legality. it is prohibited:

make unauthorized donations;

offer benefits to influence decisions;

violate rules that apply to institutional relations.

6. gifts, giveaways and hospitality symbolic gifts (up to R$ 100.00) are only allowed if:

there is no intent to exert undue influence;

prior communication is made to direct leadership;

they are properly recorded;

gifts outside these conditions must be refused or, if received unintentionally, forwarded for institutional donation.

7. conflicts of interest all travel one members must avoid situations that could create conflicts between personal and company interests.
if a potential conflict is identified, it must be immediately reported to the direct manager and/or the compliance department.

8. accounting and records all accounting records must accurately reflect the company’s transactions. it is not allowed:

manipulate balance sheets or financial records;

create parallel or undeclared funds;

use false or fraudulent documents.

9. mergers, acquisitions and due diligence incorporation, merger, or partnership processes must be preceded by due diligence to identify corruption risks or unethical conduct.

10. money laundering it is forbidden to carry out operations involving funds of doubtful origin, unjustified payments, or transactions with shell entities or risky regions.

11. donations, sponsorships and unions donations and sponsorships are only allowed with express approval from the board and a formal contract, after integrity and compliance review.

12. whistleblower channel travel one encourages reporting of any suspicious, illegal, or unethical act through its whistleblower channel:

email:
juridico@traveloneviagens.com.br

whatsapp:
+55 85 99159.7373

reports may be anonymous and are handled confidentially.

13. sanctions and disciplinary measures violation of this policy subjects the offender to disciplinary action, including dismissal for cause, contract termination, and notification of the proper authorities.

14. review and acceptance this policy will be reviewed periodically. all employees must formally acknowledge and accept it through a specific agreement.

effective date:
fortaleza, june 13, 2025.

version:
1.0

responsible:
travel one ethics and compliance committee

bottom of page